October 13, 2015

Alberto J. Sanchez 

Owner

Sanchez industria LLC

P. O. Box 10254

Tampa, Florida 33679

Mr. John S. Duncan

Director Flight Standards Service

United States Department of Transportation

1200 New Jersey Ave, SE

Washington, DC 20590

Re: Exemption request Pursuant to Section 333 of the FAA Reform Act.

Dear Director:

Pursuant to Section 333 of the FAA Modernization and Reform Act, Sanchez industria 

LLC (Si) is requesting permission to use a DJI Inspire 1, Inspire 1 v2.0 and Inspire Pro 

all weighing less than 55 lb., hereby applies for an exemption from the listed Federal 

aviation Regulations (FAR) to allow commercial operation of its Unmanned Aircraft 

Systems (UAS), so long as such operation are conducted within the under conditions 

outlined herein of as may be established by the FAA as required by section 333

Commercial operation of UAS which are equipped with camera(s) and sensors, that can 

photograph, video or live feed for Public and private use would operate in the following 

Manner:

real estate, architecture, land surveying, engineering and other related 

professional activities.

Television, public events, cinematography and news gathering.

Inspections residential/commercial structures under contract with the owners or 

local government authority.

residential/commercial/government infrastructure including but not limited to 

electrical power lines, pipelines(gas,water, etc), roads, bridges and cell towers.

assist with search and rescue operation in cases of an emergency or natural 

disaster only when the local authorities or government has requested it by 

contract or donation

Provide UAS services to local government through contracts or donated services.

Sanchez industria LLC page 1 of 5
I has been interested in photography as a hobby for the last five years and for the last 

two years been flying small drones as a hobby. The opportunity to bring together my 

interest in photography and UAV and its use it with my background in Engineering an 

exciting and challenging opportunity and the reason for forming this company.

I was a Project Manager for 10 years, and a Fire Protection Designer for 15 years and 

have held various other positions within the construction business over the past 30 

years. In my years of dealing with life safety issues in the construction industry, I have 

learned the importance of regulations and understand that many times these regulations 

were created from tragic incidents. Being a part of this new technology and the 

integration into the national air space is a challenge our company is excited to take on 

and to do so in a safe and a exemplary manner. 

To accomplish safe operation of our UAS, we believe there are three major parts. The 

first would be a pilot training program for all our Pilot In Command (PIC). All PIC will 

have at minimum a sport pilot certificate. Each PIC will go through a training and 

experience building program that will be UAS specific and must show proficiency on all 

UAS systems and flight protocols to ensure safe operation within the National Air Space 

(NAS). The PIC must also understand the flight operation protocols with automated 

systems including but not limited to: auto hover, return to home, point of interest and 

waypoint usage to develop a safe environment for all in the NAS. Our Visual Observers 

(VO) will be trained by our PIC to learn the proper communication language and rules 

that must be adhered to. Our VO will not be required to have pilot certificates but will be 

encouraged to get them. 

Second is a sound maintenance program. We will be developing a maintenance 

program using both the manufacturer’s recommendations and FAA regulations, 

including hard and electronic copies of the maintenance logs. A hard copy will be with 

the PIC at every flight. We will work with the manufacture to develop proper 

maintenance procedures.

Third is the UAS systems themselves. We believe that the DJI Inspire 1 line of quad 

rotocraft represents the very best in UAS systems. The fact that the entire system is 

made by one manufacturer helps to eliminate incompatibility issues that may plague 

other systems. The use of GLONASS + GPS system allows us to see where the aircraft 

is on a live map and give the UAS a point to hover. The showing of flight telemetry, 

Live Map and Radar shows the UAS position overlaid on a map. The Inertial 

Measurement Unit (IMU) incorporates both a 6-axis gyroscope and an accelerometer to 

monitor changes in tilt and movement. A vision positioning system assists in landings 

when GPS is not available. The Intelligent power management system shows 

remaining battery power in real time, letting you know how long you can continue to fly. 

Our firm is dedicated to the safe introduction of UAV to the NAS, and believe the 

granting of our exemption request will enhance safety by reducing risk to the general 

public and property owners from the substantial hazards associated with performing 

equivalent work with conventional aircraft.

Sanchez industria LLC page 2 of 5
As the following describes, the requested exemption would permit the operation of a 

UAS under controlled conditions in the National Air Space (NAS) under limited, 

controlled and predetermined conditions. These condition will include not flying over 

densely populated areas, and private property without the owners permission. All UAS 

will be operated within visual line of sight and will not be flown near airports without 

control tower approval or agreement and at a hight of no more than 400 feet above 

ground level. Si will provide safety enhancements to those already in usage in the 

industry presently using conventional aircraft.

The Name and address of the applicant is:

Sanchez industria

A. J. Sanchez, Owner

P. O. Box 10254

Tampa, Florida 33679

Email: Sanchezindustria@aol.com

Specific sections of 14 CFR from which exemption is sought

1. 14 CFR part 21

1.1. Si requests relief from 14 CFR part 21. All our UASs are small quad 

rotorcraft weighing less that 55 pounds during operation. The maximum 

speed is 50 mph. The maximum operation ceiling will be 400 feet while 

maintaining a minimum of 500 feet from clouds and 500 feet from nonparticipants. The (PIC) will maintain the UAV in direct line-of-sight at all times 

during flight operations with the assistance of a VO 

2. 14 CFR part 36

2.1. Si requests relief from any associated noise certification and testing 

requirements of part 36.

3. 14 CFR part 45 subpart C

3.1. Si requests relief from the size and location requirements under this section 

due to the size limitations of our UAVs. We propose to use markings as large 

as possible on the UAV as well as keep resignation information with the PIC 

during operations.

4. 14 CFR part 61.23

4.1. Si requests relief from this section so our pilots could have a minimum of a 

sports pilot certificate or private pilot certificate to operate our UAVs as PIC.

Sanchez industria LLC page 3 of 5
5. 14 CFR part 101(e) subpart (4) and (5)

5.1. Si requests relief from this section so the PIC could have a sport pilot 

certificate or private pilot certificate and still be compensated for hire and 

furtherance of a business.

6. 14 CFR 61.113(a)

6.1. Si requests relief from this section so the PIC could have a sport pilot 

certificate or private pilot certificate and still be compensated for hire and 

furtherance of a business.

7. 14 CFR 61.315(a)

7.1. Si requests relief from this section so the PIC could have a sport pilot 

certificate still be compensated for hire and furtherance of a business.

8. 14 CFR 91.7

8.1. Si request relief from this section since our UAVs have not gone through the 

FAA airworthiness process to obtain an Airworthiness Certificate as per 14 

CFR 21. We will be following manufacturer's maintenance and startup 

procedures including Si procedures and protocols to assure our UAVs are 

airworthy prior to each flight.

 

9. 14 CFR part 91.119(c)

9.1. Si requests relief from this section to allow flight levels of 400 feet and below. 

Compliance with a 400 feet maximum altitude restrictions means we can not 

comply this section. 

10. 14. CFR part 91.121

10.1. Si requests relief from this section. Our UAVs use GLONASS + GPS system 

with a vision positioning system to determine location and altitude. We have 

no means of inputing a altimeter setting. We do have the ability to input a 

maximum elevation of flight. 

11. 14 CFR part 91.151(a)(1)

11.1. Si requests relief from this section. Our UAVs have flight times less than 30 

minutes per flight due to battery life. However we are able to monitor battery 

life while in flight and can preset minimum low battery warnings. In addition 

the power management system shows when its time to fly back based on our 

UAV position in relation to the designated landing zone providing a margin of 

safety to avoid a fuel emergency.

Sanchez industria LLC page 4 of 5
12. 14 CFR part 91.405(a)

12.1. Si requests relief from this section. We will follow all manufacturer’s 

recommended maintenance and inspection protocols. Additionally, any 

service required to be performed by the manufacturer shall be done by the 

manufacturer. We will maintain a maintenance log and have a copy available 

to the PIC at all flight locations.

13. 14 CFR part 91.407(a)(1)

13.1. Si requests relief from this section. We will follow all manufacturer’s 

recommended maintenance and inspection protocols. Additionally, any 

service required to be performed by the manufacturer shall be done by the 

manufacturer. We will maintain a maintenance log and have a copy available 

to the PIC at all flight locations.

14. 14 CFR part 91.409(a)(1) and (2)

14.1. Si requests relief from this section. Our UAVs do not have airworthiness 

certificates and can not comply with this section. To assure safe operation we 

will adhere to all manufacture recommended inspections and timetables for 

inspections.

15. 14 CFR part 91.41(a) and (b)

15.1. Si requests relief from this section. We will follow all manufacturer’s 

recommended maintenance and inspection protocols. Additionally, any 

service required to be preformed by the manufacturer shall be done by the 

manufacturer. We will maintain a maintenance log and have a copy available 

to the PIC at all flight locations.

Si is submitting this petition on its own behalf. If the FAA requires any modifications to 

our section 333 exemption request, Si requests the opportunity to amend this petition to 

include any modifications the FAA may require before granting the petition for 

exemption. Si will amend our petition to meet any additional standards for the 

integration of small UAS operations into the NAS.

In conclusion we look forward to your granting of our exception request.

A. J. Sanchez

Owner

Sanchez industria LLC

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